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Taxation and Customs Union

EU Cooperative compliance programme

In July 2020, the European Commission presented an Action Plan for fair and simple taxation supporting the recovery strategy announcing plans to introduce an EU Cooperative compliance programme.

The aim of this programme is to facilitate and promote tax compliance by taxpayers based on greater cooperation, trust and transparency between taxpayers and tax administrations as well as amongst tax administrations.

The initiative covers both large multinational enterprises and small and medium-sized enterprises. In order to adapt to their particular needs and challenges, the programme has been organised into two branches:

  • an initiative to support small and medium-sized enterprises in their cross-border activities in the EU;
  • an initiative focusing on the transfer pricing risks of large multinational enterprises in the EU.

Despite a different focus, both initiatives share the same underlying objective of supporting companies in their cross-border development.

Initiative for small and medium enterprises in the EU

The Commission services have been reflecting with a number of representatives from EU Member States’ tax administrations on a possible programme to allow the tax administrations to solve together, in a preventive manner, cross-border tax issues faced by small and medium enterprises operating within the EU. A Fiscalis Project Group (small and medium enterprises) was set up in September 2020 in order to work on this programme.

The public consultation on EU Survey on a European framework for tax disputes is now closed. Results are published on this page.

A pilot project is planned to be launched in 2022: information will be posted on this webpage.

Initiative for large multinational enterprises in the EU

The programme aims to bring together tax administrations and taxpayers in a transparent environment to stimulate a preventive dialogue leading to the performance by the tax administrations of a high-level risk assessment of the transfer pricing policy adopted by the MNE groups.

The features of the programme are currently being discussed by the Commission services and a number of representatives from EU Member States’ tax administrations. A Fiscalis Project Group (Multinational enterprises) was been set up in September 2020 and is currently working on guidelines for this programme.

A pilot project is planned to be launched in Autumn 2021: information will be posted on this webpage.